Treasury, Commerce Sanctions Alert Puts Industry 'On Notice,' Law Firm Says
The joint alert issued last month by the Commerce and Treasury departments (see 2206280056) puts companies “on notice” about the types of red flags they should be monitoring for potential sanctions and export control evasion tactics, Lewis Brisbois said in…
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a July alert. While the red flags in the alert aren’t exhaustive, companies should consider them alongside “all surrounding facts and circumstances” when filing a suspicious activity report to Treasury, the firm said, or while complying with U.S. export restrictions. “At the very least, ‘covered entities’ will need to conduct a fact-intensive analysis on these potential 'red flag' indicators to ensure compliance with U.S. law,” the firm said.